State of missouri, Circuit court Third for dicide circuit March Term 1836.

County of St LouisCounty of St Louis feb

Courtney, a woman of
color complains of SamuelSamuel S. Rayburn of a plea of trespass, assault and
Batteryâ false imprisonment. For that here to how to wit an
the first day of October in the year Eighteen
hundred and thirty five, atSt LouisSt Louis in the said county, the
said defendant with forced and arms
as assault did make upon the said courtrey and her the said
courtrey did them did there he at, wound and ill he at, and her
the said courtrey did then and their saidimprisonment>without any lawful or probable so that keptdetained her so in prison there from the day last aforesaid to this day.
And said plaintiff says that at and before the times of committiny
the said several grievances she was and thiee is a free person
â that said defendant has sheld and detained â still
holds and detaing said plaintiff in slavery wherefore the plaintiff says she is greatly
injured and hath sustained damages to
five hundred dollars â etherfore she sues

County of Saint LouisCounty of Saint Louis To the State of MissouriMissouri

To the Sheriff of the county of saint Louis.

He command you to summon SamuelSamuel greeting S Ray-burn. That he be and appear before the Judge of our circuit court at the next march term thereof to be held at the eity of St LouisSt Louis within and for the county of Saint LouisSt Louis on the second monday of march next then and there to answer unto courtrey a woman of color of a plea of trespass. Assault and Battery and false imprisonment wherefore the said plaintiff says she is injured and hath sustained Damage to five Hundred Dollars - and have you then there their writ

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witnessArchibald GambleArchibald Gamble clerk of our said circuit court at office thissecond day of November A D 1835.

To the Haw Luke â Lawleys Judge of the circuit court of St LouisSt Louis county.

Yourpetitioner courtney, a woman of color, about twenty three years of age, respectfully represented, that she was born in the State of VirginiaState of Virginia and belonged to a man named Laclavd; that when quite young she said sold by him to his brother major John Gacland of the United StatesUnited States Army; who told her to Detroit in michigan; that she was kept there in flavery as nearly as she can recalled about two years; that from there she was taken by major GarlandGarland , , she believes to Fort HowardHoward Green bay in in michigan territory, where she was kept sometimes, but how long she does not remember, still held in service by majorGarlandGarland ; that from there she was taken to PrairiePrairie da Chiew in michigan ter-ritory, where she was kept about five years in the family of major Gacland; that about five years since she was told by major GarlandGarland to Mr AlexisAlexis Bay at PrairiePrairie da Chiew; that she lived with Mr Bay abou five years at St PetersSt Peters an the MississippiMississippi Revers that somewhere about four months rived Mr Bay removed to PrairiePrairie da Chiew where and brought her with him, and that she has been them with

since until a shorttime ago, when she was brought by him to the city of St LouisSt Louis, and there told by him to Mr SamuelSamuel A. Rayburn as a slave, and that said Rayburn now holds her in custody as a slave.

Your petitioner also represents that the said Alexi Bay at the time of selling her- told also to the said SamuelSamuel S. Rayburn, an infant child of hard, a log, about seven months old, named, WilliamWilliam , who was forn atSt PetersSt Peters, while she was there in the service of Mr Bay.

Your petitioner further states that she belives herself and her child to be legally entitled to their freedom; and she therefore prays that she may be permitted to sue as a poor person for her freedom and that of her now, and that your honor will such other â further order in the premises as will secure to her, her legal rights.

It Before me WilsonWilson Primm asjustice of the peace within for the county afore said personally called Courtney a woman of color, who being sworn on her oath says that the facts stated in the above peteti-tion are true.

this writ by offering to read it of theDeclaration â or ourmade by the judge of the Court the samuel Rayburn the defendant in the city of StSt Louis. LouisSt Louison the fourth day of November 1835 so which the refused to hear and acknowledged the of the same of JamesJames brothertonservice$$1.00

And the said defendant by his attorney comes â defendent therforce and injury when V. G. and says that he is not guilty of the said trespass nor any of them the said declaration mentioned in manner form as the said plaintiff hath above thereof complained and of this he puts himself upon the country.